PLP17-0017 Proposal gas station Hwy 116/Stony Point Rd

PLP17-0017 Proposal gas station Hwy 116/Stony Point Rd

Re: PLP17-0017 Proposal to build a 16-pump ARCO gas station (including 4 diesel pumps), with 24/7 convenience store and drive thru’ carwash at 7180 Hwy 116/Stony Point Road in the unincorporated area between Cotati and Sebastopol

Dear Supervisor Rabbitt, Planning Commissioner Tamura, Planning Commissioner Reed, and Planning Director Tennis Wick:

As a Cotati resident, I was concerned to hear about this proposal, and attended the preliminary Design Review public hearing on February 6.  At that meeting, the Design Review Committee sent the project back to the drawing board to be redesigned, on the basis that its “urban-style strip development and scenic corridor encroachment” is incompatible with the rural setting.  Conflict with the Scenic Corridor zoning and other conflicts with the General Plan were highlighted. I understand that as things stand at present, the project will come back for a second preliminary Design Review, timeline unknown.

I urge you to DENY the project (which requires a Use permit for the gas station; car wash is unlisted in terms of permitting) now, or to try to persuade the applicant to withdraw the proposal before the proponent invests yet more funds in redesign.

The proposed project is completely unnecessary.  There are already five gas stations within 2 miles of the site, four clustered near the Hwy 101/Hwy 116 intersection in Cotati, and another to the north on Hwy 116.  Another gas station here is not needed and would compete with and undermine existing businesses, especially as ARCO tends to undercut other gas stations’ prices.

There are currently several long-standing, small, locally-owned businesses on the site including the Pond & Garden Store, CaliKind tie-dye clothing, Martin’s Market & Deli and the Satellite Guy.  All of these would be displaced in favor of a massive corporation from out-of-county.

Design Review Committee turned back the project as being out of keeping with the rural setting.  I absolutely agree that this is the wrong site for a large gas station, regardless of design details.  It is in the Priority Greenbelt, surrounded on two sides by a Community Separator (voted in by 81% of Sonoma County voters in 2016, to “preserve rural open space and agricultural land, maintain community identities, and prevent sprawl” for the next 20 years).  This reflects the value that Sonoma County residents place on maintaining green open spaces between cities; a large gas station, carwash and 24/7 convenience store is incompatible in this location.

In addition, there are many environmental concerns about this site, which is in an area of seasonal wetlands and adjacent to open green fields.  For water for the 24/7 customers and staff and the carwash, the proponent plans to use a well; and to deal with sewage via a septic system, wastewater from the carwash, and run-off from the gas station, all on-site.  The City of Cotati stated “The ability for the site to provide adequate water and on-site sewage disposal should be clarified. The location of the proposed gas station, store, and car wash are located outside of the City of Cotati’s sphere of influence and urban growth boundary.  The City will not provide utility services to the site in the event of on-site well or sewage disposal system failure.” (J.P. Harries, May 16, 2018).

There are large ditches and culverts immediately adjacent to the property which drain to Gossage and Washoe Creeks, tributaries to the Laguna de Santa Rosa (a Wetland of International Significance); these are all less than a mile upstream of the Llano Road water treatment plant.  I have walked the SCWA trails alongside these creeks and seen western pond turtles, kingfishers, egrets, herons, merganser ducks and other wildlife.  The preliminary SUSMP calculations appear to show that there would be a total of 1.65 acres of new and reconstructed impervious surface.  What impacts would run-off from the site have on local creeks and the Laguna, including in drought and flood conditions, which as far as I can tell have not been studied?  We all know that there have been problems with the water treatment plant flooding during high rain events, without the addition of water from another new carwash upstream and expanded impervious surface areas as well. 

Sonoma County is riddled with Leaking Underground Storage Tanks, including an abandoned gas station site nearby in Cotati and others in the area which are still being monitored.  According to the EPA, “The greatest potential hazard from a leaking UST is that the petroleum or other hazardous substance can seep into the soil and contaminate groundwater, the source of drinking water for nearly half of all Americans. A leaking UST can present other health and environmental risks, including the potential for fire and explosion.” One gallon of oil can pollute 1 million gallons of water.  One pin-prick size hole in an underground gas tank can leak 400 gallons of fuel a year.  Even small gas spills are a risk to public health. https://www.jhsph.edu/news/news-releases/2014/small-spills-at-gas-stations-could-cause-significant-public-health-risks-over-time.html

The proponents sponsored a biological evaluation in 2016, which has been heavily criticized by three well-qualified local biologists I know.  The site lies within the area of critical habitat for the endangered California tiger salamander, and is close to known CTS breeding sites, but apparently the biological evaluation was done at the wrong time of year, did not follow correct protocols, and did not include the areas immediately adjacent to the site, as required.  Some of the statements in it are flat out incorrect e.g. According to Dave Cook, Senior Environmental Specialist, SCWA, the statement that “Although the adjoining property to the east has historically supported populations of California tiger salamander, it is unlikely that the populations have migrated across Stony Point Road onto the Project Area” is entirely false. I have observed CTS on Stony Point Road between the nursery and Larson’s feedlot, see attached CNDDB record. All grassland and ruderal areas in the project area are suitable CTS upland habitat. (Dave Cook, Email, 2/19/2019).  At the very least, USFWS and CDFW should be fully consulted, not bypassed based on an inadequate and incomplete study.

What would be the impacts of increased traffic with potential delays, congestion, safety impacts at the entrance and exit to the site, noise, and fumes from idling cars? Surely a gas station open 24/7 so close to Hwy 101 will draw traffic from Hwy 101 for refueling on long journeys, which would change the semi-rural nature of the area and impact Cotati’s roads and residents.

A full traffic impact analysis should be done.  The inadequate biological evaluation and the DRC’s comments on the lighting plan do not give me any degree of confidence in the other studies, including on air quality and greenhouse gas emissions, which should also be reviewed by BAAQMD and other appropriate agencies in a full Environmental Impact Report, if the project is considered at all.

With increasing awareness of the climate crisis and the need to reduce greenhouse gas emissions, with the sale of gas stations plummeting and the sales of electric cars rising rapidly, especially in Sonoma County, why would anyone want to build a gas station now anyway?  This proposal seems counter to all the efforts currently being made to reduce the use of fossil fuels, reduce greenhouse gas emissions, and take positive action on the climate crisis.  Sonoma County has taken a lead in this area and approving a new gas station in a rural area between cities would be a retrograde step. 

Who will be responsible for paying for and cleaning up the site when it becomes obsolete?

What would be the long-term, cumulative and potentially growth-inducing impacts of a project of this size at this site?

I was concerned to learn that only neighbors within 300 ft. of the project site have to be informed by the County.  Yet, neighbors in the adjoining rural areas further away than 300 ft. would be heavily impacted by traffic, noise, air pollution, and bright lights, 24 hours per day, 7 days per week, which would be detrimental to their overall quality of life and in conflict with the rural values that drew them to the area in the first place.  Those I have spoken with are unanimous in their opposition to this project.

Design Review Committee highlighted a list of conflicts with the General Plan. There are many others as well.

Lastly, I attach a Google satellite aerial view of the location and a photo of the land immediately south of the site.

I hope that you will do everything you can to ensure that this project is denied before the proponents spend even more money on design and before it is too late.

I look forward to hearing from you.  Thank you.

Sincerely

Jenny B.

Cotati, CA 94931

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